The easy answer to Sir Brian Leveson's problem has always been floating temptingly out there, just over the Irish Sea. Dublin's press-council-plus-ombudsman system already has all the Fleet Street papers who sell copies in Ireland as more-or-less voluntary members, without fear or overmuch fury. It also features a novel kind of statutory underpinning because both council and ombudsman are mentioned in the 2009 Defamation Act, which theoretically means members qualify for lower libel damages because they're fair and responsible citizens.

What could be neater? A solution embraced and working that provides real incentives to join? Even Richard Desmond has signed up. No wonder the Times is predicting that the Leveson report, when it arrives, may boast a bright green cover and shamrock trimmings. It will be billed, apparently, as "light-touch regulation", a mild, modest blend of this and that no one need get too worked up about.

Unless, of course, you want to light the blue touchpaper and retire immediately: because all is not quite as it seems. To begin with, the Irish regime does not involve fines as sanctions – just printed corrections and adjudications. It does not, in a strict sense, investigate anything beyond individual complaints from those personally affected. It is fundamentally – like almost every other press regulation body in the western world – a complaints-handling organisation. It takes up cases only after a complainant has failed to get satisfaction from a newspaper. It does not, in general, consider wider issues or secondhand beefs. Nor is membership of the system complete. Voluntary means voluntary and a number of smaller papers and magazines haven't joined – the Private Eye exception on a rather bigger scale.

Every one of those points (well charted in a Reuters Institute study) falls way short of the overarching Leveson diagnosis of what's needed. Many of them, indeed, are more rigorously addressed by the UK press's own scheme for a upgraded Press Complaints Commission bolted together by contract law. The Irish ombudsman – horror of horrors! – is a twinkly, humorous journalist turned politician, John Horgan. He's long on charm and common sense. But he is still a journalist by instinct – not at all the "independent" voice that Leveson prescribes. Nor is the press council itself especially independent by London lights. Six of its nominated members represent the press in various ways. Seven are appointed because they don't, but a former diplomat as chair, sitting with three academics and three lawyers, isn't necessarily a blend that speaks to a wider public.

And as for the light-touch underpinning, remember two heavyweight things. One is that the press council is accountable to the Dáil because the justice minister can revoke the order recognising it in the Defamation Act – with parliamentary scrutiny of its performance due in 2014-15. Another is that, in a crisis, the justice minister thinks he (and not the communications minister) has an obligation to intervene. So when the Irish Daily Star published those topless pictures of the Duchess of Cambridge, the ministry of justice was into action in a flash, ordering a review and threatening to introduce a pretty draconian privacy bill that was lying ostentatiously on the minister's desk.

There's independence and independence, in short. There's a not-entirely-innocent underpinning that can lead to bigger things in a trice. And there's always a threat or two of something worse lurking not so far in the background.

The Irish solution has flourished so far because, most of the time, it deals in persuasion – because it demands few of the penalties and obeisances Leveson has on his list. But don't think (small country/big country) it would function so sweetly over here, especially when Horgan himself adds one more caveat – that a solution should be negotiated and agreed as the Irish example was: not imposed by fiat.